ML19308C382

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Deposition of Jf Streeter (NRC) on 790926 in Bethesda,Md. Pp 1-63.NRC Confirming Deposition Schedule Encl
ML19308C382
Person / Time
Site: Crane 
Issue date: 09/26/1979
From: Folsom F, Hebdon F, Streeter J
NRC - NRC THREE MILE ISLAND TASK FORCE, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
References
TASK-TF, TASK-TMR NUDOCS 8001230352
Download: ML19308C382 (66)


Text

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O NUCLE AR REGUL ATO RY COMMiS5!CN i

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IN THE M ATTER OF:

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JOHN F.

STREETER i,

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Place -

SETHISDA, MD.

I Date -

Wednesday, September 26, 1979 Pcge?

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-____________x

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In the Matter of:

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HREE MILE ISLAND i

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SPECIAL INTERVIEWS I

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DEPOSITION OF JOHN F.

STREETER 8

Room 9109 9

Maryland National Bank Bldg:.

7735 Old Georgetown Road 10 Bethesda, Maryland 11 Wednesday, September 26, 1979

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9:15 a.m.

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BEFORE:

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For 'he Nuclear Regulatory Commission:

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FRED HEBDON l

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1 WITNESS:

EXAMINATION O

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Streeter 3

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MR. HEBDON: Would you raise your right hand,

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2 please?

(v) 3 Do you swear or affirm that the testimony you are about

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4 to give shall be the truth, the whole truth, and nothing (s')

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but the truth, so help you God?

6 MR. STR EETER: I do.

7 Whereupon, 8

JOHN F. STREETER 9

was called for examination and having first been duly sworn, 10 was examined and testified as follows:

11 EXAMINATION 12 BY MR. HEBDON:

13 0

Have you read and do you understand the letter la sent to you by Mr. Rogovin concerning this interview?

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15 A

Yes, I have and I do understand it.

16 0

Okay.

For the record, I would like to have this 17 letter included in the record at this point.

18 (The letter follows )

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vuv-In Reply Refer to:

I NTFTM 790914-02 MJ. John F. Streeter

, Region III v, -

U.S. Nuclear Regulatory Commission

(_)

Office of Inspection and Enforcement 799 Roosevelt Road Glen Ellyn, Illinois 60137 (m

Dear Mr. Streeter:

j I am writing to confirm that your deposition under oath in connection with the accident at Three Mile Island is scheduled for September 26, 1979 at 9:00 a.m., in Room 9109 MNBB offices of the NRC/TMI Special Inquiry Group.

This will also confirm my request for you to bring with you a copy of your resume and any documents in your possession or control regarding TMI-2, the accident or precursor events which you have reason to believe may not be in official NRC files, including any diary or personal working file.

The deposition will be conducted by members of the NRC's Special Inquiry Group.on Three Mile Island.

This Group is being directed independently of the NRC by the :aw firm of Rogovin, Stern and Huge.

It includes both NRC personnel who have been detailed to the Special Inquiry Staff, and outside staff and attorneys.

Through a delegation of authority from the NRC under Section 161(c) of the Atomic Energy Act of 1954, as amended, the Special Inquiry Group has a broad mandate to inquire into the causes of the accident at Three Mlle Island, to identify major problem areas and to make recommen-dations for change.

At the conclusion of its investigation, the Group will issue a detailed public report setting forth its findings and recommendations.

,(_)

Unless you have been served with a subpoena, your participation in the deposi-tion is voluntary and there will be no effect on you if.you decline to answer some or all of the questions asked you.

However, the Special Inquiry has been given the power to subpoena witnesses to appear and testify under oath, or to appear and produce documents, or both, at any designated place. Any person deposed may have an attorney present or any other person he wishes accompany him at the deposition as his representative.

The Office of the General Counsel of NRC has advised us that it is willing to send an NRC attorney to all depositions of NRC employees who will represent you as an individual rather than represent NRC.

Since the NRC attorney may attend only at your affirmative request, you should notify Richard Mallory (634-3224) in the Office of the General Counsel as soon as practicable if you wish to have an NRC attorney present.

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You should realize that while we will try to respect any requests for

' confidentiality in connection with the publication of our report, we can

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=ake no guarantees.

Names of witnesses and the information they provide i._/

may eventually become public, inasmuch as the entire record of the Special Inquiry Group's investigation will be made available to the NRC for what-ever uses it may deem appropriate.

In time, this information may be made available to the public voluntarily, or become available to the public (o) through the Freedom of Information Act.

Moreover, other departments and agencies of government may request access to this information pursuant to the Privacy Act of 1974.

The information may also be made available in whole or in part to committees or subcommittees of the U. S. Congress.

If you have testified previously with respect to the Three Mile Island accident, it would be useful if you could review any transcripts of your previous statement (s) prior to the deposition.

Thank you for your cooperation.

Sincerely,

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Mitchell Rogovin, Dire ctor

-5, NRC/TMI Special Inquiry Group

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BY MR. HEBDON:

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2 0

Do you have any questions or comments concerning 3

that letter?

([])

4 A

Only one question.

I note that it says, the last 5

sentence of the first paragrapht- "This will also confirm my 6

request f or you to bring with you a copy of your resume

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7 and any documents in your possession or control regarding 8

TMI 2 the accident or precursor events which you have reason 9

to believe may not be in official NRC files, including any 10 diary or personal working file."

11 Now I have in my possession and am willing to provide 12 you with some notes of telephone conversations that I have 13 had with the Davis-Besse personnel specifically concerning 14 the loss of pressurizer level indication review that we 15 performed.

16 I also have in my possession documents which we used in 17 cur review which are B&W and Davis-Besse's evaluation of the 13 loss of level transient.

19

-I do not know if those documents are proprietary or not.

2D So although I would be willing to identify them as f ar 21 as date and people, if you wish, I would be hesitant to 22 provide you with copies in that I don't know if they are 23 proprietary.

24 0

Well, if they are in your records and they were not O) designated as proprietary when they were submitted, then I

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think you would have to assume that they are not.

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2 A.

Well, we can go on that assumption.

3 0-If you would then provide those documents.

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4 guess the easiest thing would be to go ahead and provide 5

them right now, if you have copies.

6 A

I don't have copies.

I have thcse documents.

I 7

imagine that we might as well go off the record'while I'm

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8 ge tting these.

9 MR. HEBDON: Okay, let's go off the record.

10 (Discussion off the record.)

11 MR. HEBDON: Let's go back on the record.

12 BY MR. HEBDON:

13 0

Now you have provided me with some documents and 14 some copies of some handwritten notes that appear to be 15 telephone logs.

If you would have copies made of these 16 documents and provide them to us by mail at a later date, I 17 think it would help facilitate our use of those documents.

IS A

I will do that.

19 0

Okay, thank you.

Would you please state your name 20 for the record?

21 A

John F. Streeter.

22 0

?'h a t is your current position?

23 A

I am presently section chief, Nuclear Support 24 Section 1 within the reactor operations and nuclear support

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25 branch in Region 3 of the office of inspection and enforcement.

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0 What was your position in late 19777

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2 A

Late 1977, I was the project inspector for 3

Indian points units 1, 2, and 3, and Millstone Unit 2 in

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4 Region I.

5 0

When did you take over your present position?

6 A

May 10th, 1978.

7 0

Does Mr. Tambling work for you?

8 A

No, he does not.

9 0

Does Mr. Creswell work for you?

10 A

He does not work for me now.

He did work for me 11 up until the beginning of August of this year.

12 0

Did Mr. Harpster work for you?

13 A

No, he did not.

14 0

To whom do you report?

15 A

To Robert S. Heishman, the chief of reactor 16 operations and nuclear support branch.

17_

0 Would you describe your employment history, 18 including positions held at the NRC.

19 A

Beginning in 1961, that was my initial involvement 20 in the nuclear field in the United States Navy.

I spent 21 5 years in the Navy.

22 MR. HEBDON: Excuse me.

Let's go of f the record.

23 (Discussion off the record.)

24 T4R. HEBDON: Let's go back.on the record.

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BY MR. HEBDON:

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Okay, would you go ahead and explain your employment 3

history?

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- 4 A

In 1961, I began my involvement in the nuclecr 5

field in the United States Navy.

I spent five years in the 6

Navy as a reactor technician and reactor operator and 7

instructor at one of the prototypes for the Navy.

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8 After discharge, I worked for a period of three years at 9

Gulf General Atomic in the capacity of shift supervisor, 10 senior reactor operator for a group of three research 11 reactors, the Trenton research reactors.

12 S ubsequent to that, I completed my college education.

13 Then was employed for approximately a year with Douglas 14 United Nuclear at the Hanford reservation.

O 15 At the N Reactor in 1971, I began my employment with the 16 NRC in, at that time, the division of reactor standards.

17 For two years during that time I functioned primarily es a 18 coordinator for the issuance of regulatory guides, rules, 19 and regulations and other tasks in the reactor standards 20 group.

21 In 1973, I went to work for Region I in King of Prussia, 22 Pennsylvania, then spent five years there as a reactor 23 inspector.

24 Initially, in the technical support group, subsecuently,

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25 most of my time was spent in the pro ject group as a project Ok)

621.01.6 8

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inspector.

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2 In 1978, I transferred to Region 3 in my present capacity 3

as section chief of nuclear support section 1.

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I have here at your reauest a copy of my resume, which 4

5 summarizes what I have just said.

It is up to date.

6 MR. HEBDON: I would like to have this resume 7

included in the record at this point.

8 (The resume followss) 9 10 11 12 13 14

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15 16 17 19 19 20 21 22 23 24

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s JOHN F. STREETER

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9 Organization:

U.S. Nuclear Regulatory Commission JF STREETER i

Office of Inspection and Enforcement Region III

Title:

Section Chief, Nuclear Support Section 1 Grade:

GS-15 Birth Date:

6/15/41 Education:

U.S. Naval Nuclear School, 1962 A.A. Mathematics, San Diego Mesa Junior College, 1968 B.A. Economics, Stanislaus State College, 1970 Experience:

1978 Section Chief - Supervise reactor inspectors who provide engineering support on reactors in operation and in test status.

(NRC) 1973 - 1978 Reactor Inspector - Project responsibility for four Pressurized Water Reactors.

(NRC) 1971 - 1973 Reactor Engineer, Office of Plans and Programs, Directorate of Regulatory Standards - Assisted in the coordination of the standards writing and rule-making activities of the Directorates of Regulatory Standards and Licensing. Was involved in coordinating portions of licensing reviews of nuclear plants and in developing amendments to the Rules and Regulations.

(NRC) 1970 - 1971 Assignment Supervisor, Douglas United Nuclear, Inc., -

Primary duty was to certify as a Control Room

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Supervisor.

1967 - 1968 Senior Reactor Operator, Gulf General Atomic - Performed 1964 - 1966 experimental reactor setups, operated three TRIGA l

research reactors, and directed the shift activities l

of other reactor operators.

I 1963 - 1964 Reactor Technician and Operator, USS Theodore Roosevelt I

(Submarine) 1962 - 1963 Reactor Operator, Technician, and Instructor, U.S. Naval Nuclear Power Training Unit - Operated and supervised O.

the operation of the reactor console and performed pre-critical, shutdown, and instrument tests.

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621.01.7 9

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BY MR. HEBDON:

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2 0

What I'would like to discuss next with you is an 3

incident that occurred at Davis-Besse Hon September 24th,

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4 1977.

I am particularly interested in what knowledge or 5

what information'you had concerning that event prior to the 6

accident at TMI specifically, prior to March 28th, 1979,

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7 what knowledge did you have concerning the incident that 8

occurred at Davis-Besse on September 24th, 1977?

9 A

My knowledge of that event came about primarily 10 as a result of Jim Creswell's review of the event while he 11 was working for me.

Or since I have to review his work, 12 I became aware of his concerns and various aspects of the 13 event.

14 This was begun approximately September, 1978, about a O

15 year after the event when Jim Creswell looked into a couple 16 of aspects of the event.

17 So as to what my knowledge of the event was prior to the 13 TMI incident, I knew basically what occurred.

I guess I 19 could say more than basically.

I had some knowledge of what 20 transpired during that event.

21 And we were in the process, either had resolved or were in 22 the process of resolving Jim Creswell's concerns at that time.

23 MR. FOLSOM: Let me ask a couple of questions.

24 BY MR. FOLSOM:

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25 0

Sefore Creswell raised his concerns, what knowledge O

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did you have of the event?

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2 A

I knew -- we ll, what I kne'.i was that they had a 3

loss of coolant accident in that the ps.ver-operated relief

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4 valve stuck open, that they had a depressurization and that 5

the event had been reviewed within Region III>

6 And there were no outstanding issues at that time related 3 -

7 to the event.

8 BY MR. HEBDON:

9 0

Prior to Mr. Creswell's concerns, did you recognize 10 it as a loss of coolant accident or a depressurization 11 accident?

12 A

I do not know if I ever identified it as a loss of 13 coolant accident or was aware that anyone else did.

But if 14 you have a hole in the primary coolant system, no matter rk-15 where it is, i t is a LOCA.

16 SY MR. FOLSOM:

17 O

Now Creswell reported to you.

He was your 16 s ubordina te ?

19 A

Yes, he was.

20 0

And that is how his concerns were brought 21 specifically to your attention.

22 A

That is correct.

23 MR. FOLSOM: Okay.

24 BY MR. HEBDOM:

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rlhat significance did you attribute to that n

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incident?

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2 A

First of all, it was an undesirable event.

There is 3

no denying that.

Everyone that I am aware of recognized that

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4 from the outset, of course.

5 It was also recognized as not a routine event, a rather 6

unusual event.

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7 The significance of'that, of course, is the objective of 8

one of these PWRs is to keep it pressurized.

You depressurize 9

it.

Then what you are doing is you have the potential for 10 removing the heat sink away from it and draining the fluid 11 and causing fuel damage and a release of radioactive 12 material to the environment.

13 0

Did you consider this to be one of many incidents 14 that occurred at plants from time to time, or did you 7-V 15 consider this to be a very severe incident that was much 16 beyond, or at least beyond the level of severity, either 17 actual or potential, of most incidents that occur at power 18 plants?

19 A

I considered it in relation to other events that 20 occurred in power plants.

I considered it to be very 21 unusual and very significant.

22 It is not something that occurs routinely at other plants.

23 I don't know of any other plant, with perhaps one exception, 24 that ever experienced an event such as that.

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25 It has long been recognized by people that power-operated

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I6.21.OI.10 12 IiEEgsh-1 relief ' valve has a potential for sticking open.

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2 However, at the same time people recognize that there is 3_

a blocked valve present which people, once they recognize the

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4 event, can cope with it by closing the blocked valve.

5 0

You said with the exception of one other incident.

6 What was that other incio'ent?

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7 A

I do not have~ direct knowledge of the event.

But 8

only rather recently, I believe that Oconee or some plant 9

down in Region II some time ago had some trouble with one 10 of these power-operated relief valves, and that is the 11 extent of my knowledge.

12 0

Before we go on to talk specifically about Mr.

13 Creswell's concerns, I have here a copy of a note to Mr.

14-Karl Seyfrit from Mr. D.F. Ross of NRR.

The title is 15

" Davis-Besse 1, Abnormal Occurrence," and it is dated 16 October 20th, 1977.

17 Have you ever seen that memo?

18 A

Yes, I have.

19 0

Under what circumstances and when?

20 A

As you are aware, I missed your visit to Region 21 III when you were there interviewing people.

I had an 22 opportunity to review Dick Knopp's deposition at that time.

23 This particular item-was inclu fed as an exhibit.

That was 24

'the first time that I had ever seer the memorandum.

That was

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25 approximately two weeks ago at most.

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'621.01.11 13 HEE:gsh 1

0 So prior to-that particular time, you had not seen

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2 this memo, to your knowledge?

3 A

I am positive I have not seen the memo prior to that O

4 time.

5-0 Let's go on and discuss Mr. Creswell's concerns, 6

since it appears that you were not directly involved with 7

the actual response to'the incident that occurred at 8

Davis-Besse.

9 You mentioned that you were aware -of Mr. Creswell's 10 concerns about the September 24th, 19 77 incident.

Would you 11 describe what your understanding of those concerns is?

12 A

The concerns of Jim Creswell, to my unde standing, 13 amount to two areas.

One of the areas was that he was 14 concerned that during the September event, the operators O

15 at Davis-Besse turned off the high pressure injection 16 pumps before they had knowledge of the LOCA; specifically, 17 the power-operated relief valve.

18 At that time, to the best of my knowledge, the pressure 19 was below the shut-off head of those pumps and the operator 20 made a dec4.sion to turn the pumps off based upon pressurizer 21 level indication.

22 The other concern that Jim Creswell had related to the 23 September 24th event related to an indicated delay in the 24 injection in one high pressure injection lag at Davis-Besse.

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621.01.12 14 hiEEgsh 1

injection pump he had a general concern about people r

2 realigning equipments specifically, the make-up containment 3

isolation valve,.before they knew what was going on.

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That is a summary of his concerns.

5 0

Do you know if his concerns were eventually resolved 6

with respect to this particular incident?

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7 A

All but one,'and they have been resolved to the 8

satisfaction of the licensee.

9 However, we are this week -- as a matter of fact, I am 10 winding down our review of the issus related to the delayed 11 injection of one of the high pressure injection legs.

12 O

What has been the conclusion with respect to that 13 concern?

14 A

The conclusion that we will probably draw from that (b/~)

4 15 is that although there is no evidence to say that the 16 delayed injection in that leg was not real, the delayed 17 injection did not invalidate the assumptions made' in the 18 ECCS analysis.

19 0

Do you know 'if Mr. Creswell considered the other

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20 concerns other than this particular one to be resolved?

21 A

He considered the issue aoout the realignment of 22 components.

The example I gave was the make-up of the 23 containment isolation valve to be resolved, and that is 24 documented in the report.

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25 At the time of his last inspection, he had not resolved the O

7621.01.13 15 HEE gsh I

concern related to securing the high pressure injection pump

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2 or the delayeo injection.

3 Those two issues were still open.

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4 BY MR. FOLSOM:

5 0

When was his last inspection report?

6 A

His last inspection was February 5 through 9, 1979.

7 BY MR. HEBDON:

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8 0

Nou you mentioned that his concern about the 9

high pressure injection being secured had not been resolved.

10 A

That 13 correct.

Had not been documented as being 11 resolved.

I should clarify that.

12 What I mean-by that is that the issue was first raised 13 in September of 1978, a year after the event.

14 Subsequent to that, in December of 1978, the licensee had 15 taken some corrective action to revise procedures to 16 rectify the concern.

Jim Creswell and myself reviewed those 17 procedures at the site in December.

Jim Creswell believed 18 that the corrective action was not adeauate in that it did 19 not give the operators enough directions as far as securing 20 the high pressure injection pumps.

21 And we indicated that more additional revisions to the 22 procedure were in order.

23 Those were subsequently made the first part of January.

24 However, they were not reviewed during the inspection in 0

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I.have subsequently reviewed them within the last month

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2 and I determined that had I looked at them the first part 3

of January prior to the TMI event, I would have been satisfied

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4 with the licensee's corrective action.

5 However, those have been superceded, as you know, by 6

the instructions and bulletins and everything for securing 7

high pressure injection pumps.

8 0

How similar or how different are the precautions 9

that were included in the procedures in January to the 10 precautions and limitations that have been included in the il procedures as a result of the Three Mile Island accident?

12 A

Mell, I would have to still believe that the 13 precautions that they put in are probably adequate because 14 what they said was, you can only secure the high pressure D

15 injection pumps only if you know where the break is, only 16 if you have a certain amount of low pressure injection 17 flow going, and only if the pressure is below the shut off 18 head of the high pressure injection pumps.

19 Those are the only situations.

20 So if you are above the shut-of f head, those pumps aren't 21 doing anything but dead-heading on you.

22 In Davis-Besse's case, th6t is 1700 pounds.

In an 23 additional statement that it was always in the procedure is 24 you don't turn them off until the pressurizer level was

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25 re-established.

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621.01.15 17 1

Now the new guidelines bcsically say that in addition to HEE gsh 1

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2 saying that your pressurizer level is re-established, that 3

you have 50 degrees of subcooling before turning them off.

4 So I don't see a great deal of di.fference between the

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5 two guidelines.

6 O

The revision that became as a result of Three Mile 7

Island has the stipulation of 50 degrees of subcooling?

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8 A

Yes, it does.

9 0

So that, to your mind, was the biggest addition 10 that was made to those precautions as a result of the 11 Three Mile Island accident?

12 A

That's right.

For that particular item, there 13 were additional modifications in their loss of coolant 14 procedure which was reviewed by NRR representatives and r(-)

15 others that about, I guess, doubled or tripled the size of 16 the document for this particular area.

17 That is the biggest diff erence.

18 O

Are you aware of concerns that Mr. Creswell had 19 associated with the November 29th, 1977 incident at,

20 Davis-Besse?

21 A

Yes, I'm very much aware.

Those concerns, of 22 course, preceded the concerns that later came about as f ar 23 as the September event.

And to my knowledge and my 24 understanding, they were never directly connected in

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25 pursuing the November event.

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7621.01.16 18

[ HEE 'gsh-1 It aroused the curiosity of the inspector, so he went back

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and looked at the September event.

But they were different.

3 0

Do you know why Mr. Creswell was reviewing these

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4 two events?

Was that a normal function of his job?

5 A

One of them was.

The November, '77 event was 6

being reviewed by Jim Creswell at the request of Tom

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Tambling, the project 1nspector.

8 The reason that he was requested to review the event was, 9

first of all, he was a nuclear support inspector at that 10 time and he had some inspection activities over Davis-Besse.

11 At that time, he had been assigned to the star-up test 12 program at Davis-Besse.

So it was logical if Tom Tambling 13 wanted something done, he would request our group to do it 14 and Jim Creswell.

13 The Novemoer, >.77 event, the licensee experienced shut-down 16 to about 50 percent power.

They did an operator error.

17 They induced a loss of off-site power condition.

And since 19 the natural circulation test had not yet been performed in 19 the start-up program, the licensee wanted to take credit 20 for that event to satisfy the provisions of the natural 21 circulation test committed to an FS AR.

22 So Tom Tambling's request for Jim Creswell was reviewed, k

23 the data associated with the November event, to see if it 24 adeouately addresses and satisfies the requirements in the 25 natural circulation tests.

n l

v

7621.01.17 19 HEE gsh i

That is what commenced the involvement. And had it not

~

()

2 been for-the licensee's request to satisfy that provision 3

of-the natural circulation test, it would have been unusual, 4

although not prohibitive, for Jim Creswell to review that

()

5 event.

6 The September event, that was somewhet unusual in that 7

the event had been reviewed by Region III personnel having 0 -

8 closed out, to the best of my recollection, there were not 9

open items associated with the event.

10 But because Jim Creswell, looking back, believed that 11 something wasn't quite right, he pursued that.

12 Inspectors are given that latitude if they feel that 13 there is a problem after discussing it with their supervisor 14 to pursue those issues.

15 I was aware that he was doing it and I gave my permission 16 to do it.

17 18 19 20 21 22 23 24 A(_)

25

7621.02.J 20 e' HEE gsh I

BY MR. FOLSOM:

()

2 0

I'm going to ask a question from a layman's 3

standpoint.

(]}

4 You tell me that the licensee was asking to have its 5

actions taken with respect to the November incident as a 6

substitute for the natural circulation test?

3 -

7 A

Yes.

8 0

Explain that to me, please.

9 A

What happened, first of all, the start-up test 10 programs at these power plants, we have in the nuclear 11 support section,-one, we have the responsibility for 12 inspecting of start-up. te st programs.

13 They have a su.-ies of tests in which the licensee i~s 14 committed in the FSAR to conduct a nuclear power escalation (J

s s

15 sequence. Not one of those tests is a natural circulation 16 test where what they do is with no force flow in the

-17 reactor coolant system.

18 -

They bring the reactor to power and they operate it at 19

-some low power level to show that the natural circulation 20 capability of the system --

21 Now what happened in the November event was the natural 22 circulation was established.

And so instead of conducting 23 another test, if there was enough evidence from that transient l

24 to demonstrate the natural circulation capability, then it is I

s'%

(_)

25 reasonable, in my opinion, to allow the licensee to say, I

(

l l

1

F621.02.2 21

>-HEE gsh I

have satisfied that testing requirement because I have all

()

2 of.this data and I can show you that I met the acceptance 3

criteria for that test.

f( )

4 And it is, in my opinion, not unreasonable to do that.

5 But the conclusion was that the evidence, the documentation 6

was not available to demonstrate the satisf actory completion 7

of that test.

8 This was concurred in by NRR subsequently and then the 9

licensee.was directed to perform that test.

.10 MR. HEBDON: All right.

11 BY.MR. HEBDON:

12 0

Would.you go on then with your description of your 13 understanding of Mr. Creswell's concerns associated.with this 14 incident?

15 A

The primary concern associated with that event was 16 that the pressurizer level indication went below the lowest 17 indicator level for some period of time, for approximately 18 five minutes, or something like this.

And after that time 19 it recovered.

20 Jim Creswell considered that to be a very unusual 21 condition.

He considered that because the level went below 22 the lowest indicated level, that the licensee should do en analysis to determine how low the pressurizer level actually 23 24 went.

A

(_)

25 The ultimate concern of Jim Creswell was did the potential

()

l

1 22 1621.02.3 HEE gsh I

exist for training the pressurizer.then forming steam

()

2 blockage in the steam generators which' would inhibit natural 3

circulation capability of the reactor.

)

4 O

Did Mr. Creswell at any time indicate to you that A("./

5 he felt that there was a relationship between the concerns that 6

he had with respect to the November 29th incident and the

>~

7 concerns about the September 24th incident.?

8 A

I do not recall him relating to me any relationship 9

between those two events.

10 Of course, it was obvious to me that in both events you 11 are. talking about pressurizer level. That is one thing that

_ 12 you are concerned about, and the reactor coolant system 13 pressure.

14 And in that sense, I had enough knowledge to know that 15 there was a relationship such as that.

16 0

Do you know if Mr. Creswell's concerns about the 17 November 29th incident were resolved?

18 A

Yes.

These were sometime later, approximately a 19 year later.

A very detailed. series of events led up to 20 the resolution of those.

21 The licensee performed caveral analyses before the last 22 one in October of last year.

23 That finally put us at ease that the lowest pressurizer 24 level attained was something about three f eet below the O(_/

25 lowest indicator that indicated that there was four feet of

()

F621.02.4-23 HEE gsh I

water above the --

()

2 0

This was during the_actuel transient?

3 A

During the actual transient.

()

4 0

Did they' perform an analysis of how low the level 5

.could have gotten under worst case conditions?

6 A

They did do that.

I feel,.for the record purposes, 7

to go through something that takes a little time to try to

~

8 explain to.you how this all developed.

9 In November '.77, the event occurred that we are discussing

.10 with the loss of off-site power, the loss.of pressurizer

.11 level indication from the power level of about 50 percent 12 power.

13 The licensee, from all of the information available to 14 me, it indicates that the licensee recognized that to be an O

15 unusual event.

They were pursuing it with their nuclear 16 steam supplier, B&W, to determine the means to rectify the 17 situation.

18 In the process of those conversations, our inspection was 19 conducted, which I have described, by Jim Creswell, and Jim 20 Creswell also identified that they hadn't completed their 21 evaluation.

22 And at that time, he got a commitment from the licensee 23 to perform an evaluation to show how far the it el of 24 pressurizer, the level actually went.

O 25 Up to that time, the licensee's concerns were more how do

(_/

L l

L

7621.02.5 24 HEE gsh I

we prevent this from occurring in the futures not how bad r( )j 2

was the situation.

3 0

Well, why did they f eel that it needed to be

()

4 prevented in the future.?

5 A

Well, there is no one that I know of that maintains 6

that the loss of pressurizer level indicati~on during an 7

anticipated operational occurrence is a good thing.

'~

8 That is.one of your primary indicators of the conditions in 9

the RCS besides pressure.

10 And this was readily recognized by the licensee.

Il 0

Was it recognized as an unreviewed safety issue?

12 A

No, it wasn't.

As a matter.of f act, looking back 13 sometime later, it was brought up that this type of event 14 had occurred at several other B&W f acilities.

15 It was a generic issue, Ranch Seco, Arkansas Unit 1, and 16 Three Mile Island.

17 At least those, to my knowledge, it came.out, had 18 experienced these.

19 As a matter of fact,.also, there was also an indication 20 that prior to operation of Davis-Besse, B&W had informed 21 Davis-Besse of this generic problem and had suggested that 22 it do a couple of things to assure that they didnt' lose 23 the indicated level.

24 These events I have been describing have been reviewed by b

ss 25 the various regional offices.

No one, B& W, the licensees, or O

1

7621.02.6 25 HEE gsh I

regional personnel or their contacts with NRR, it had not IO

(_/

2 been identified as an unreviewed. safety question.-

3 MR. FOLSOM: May I ask a question?

()

4 BY MR. FOLSOM:

5 0

I get the picture that level indication --- now I 6

have never been in the operating room.when the plant was

~

7 going.

8 Where do I look for that level indication?

What is it?

9 A

lt is a recorder. You will see a strip chart 10 recorder and also you will see a meter. It will be an 11 elongated, rectangular in shape meter that.will give that 12 indicator level.

13 And then for record purposes, they will have it on a 14 strip chart recorder that will show that.

O 15 MR. FOLSOM: Thank you.

16 BY MR. HEBDON:

17 0

Would you go on then with your chronology?

18 A

Starting with then Jim Creswell requesting the 19 analysis, the licensee had to go through several iterations 20 of that because their analyses did not satisfy Jim Creswell.

21 And when I'm saying did not satisfy Jim Creswell, of 22 course reviewing his work, I concurred in that.

23 And so it was in a sense, although he identified the 24 issues, it was unacceptable to us.

25 Now they did several analyses to determine how the

()

t l

l t

t

-l

621.02.7 26 HEE gsh I

low the pressurizer level actually went during that event..

()

2 That's what they were in the process of doing.

They did

~3 analyses within a couple.of months.

They did another one in

(])

4 the summer.

They did another one in September.

5 These are the documents that'I will provide you copies of 6

that we referenced at the beginning of the session.

And then 7

they finally did one in October to satisfy us that they 8

actually knew how low the level went.

9 Also, at the same time, there was another matter that was 10 going on when the event occurred in November, 3.77.

The 11 licensee, as I said, was interested in preventing this 12 from occurring every time that they had a transient such as 13 this.

14 So they pursued two avenues.

One is on the blowback 15 setting of the main steam safety valves.

The experience has 16 indicated at B&W facilites that they are sensitive to the 17 blowback setting on the main steam saf eties.

18 What happens is your safety valve lifts, the lowest one 19 lifts at maybe 1,050 pounds.

The best blowback setting that 20 they have found is about 3 percent.

21 So you're talking about the lowest main steam pressure 22 that you will have in there is about 1000 pounds.

It will 23 reset and then if it goes up again, they will lift.

24 What B&W found was the blowback settings on those valves

/~T

()

25 were allowing the main steam safety valves not to reseat

/N N.]

7621.02.8 27 HEE gsh I

until something below 900 pounds.

()

2 This meant that you were removing a great deal of energy 3

on the secondary' side from the RCS and it was contracting

()

4 the fluid in the reactor coolant system.

.You get shrinkage 5

and your level is going down to pressurizer.

6 0

Now they found this to be a general problem or they

~

7 found this to be a opublem 'specifically at Davis-Besse?

8 A

This was generic.

This was one part of the 9

notification that B&W made.to Davis-Besse prior to their

.10 start-up.

They said essentially, the memo said that we 11 found that we've had problems that other plants with loss 12 of pressurizer level indication -- here are the primary 13 causes, in our opinion.

14 And those were the blowback setting and then the other b) 15 one was the overfeed.

16 0

Could we pursue this blowback setting f or just a 17 second?

You say that B&W informed Davis-Besse of this 18 prior to their start-up?

19 A

Yes.

20 0

Did they take any action at that time to correct 21 the problem?

22 A

No, they didn't.

23 0

Why not?

24 A

Well, I don't know, to tell you the truth.

I did

()

25 not become aware of this recommendation to Davis-Besse until O

m.

421.02.9 28 HEE gsh 1

an investigation took place in February of this year as a

()

2 result of Jim Creswell's investigation.

3 0

Would you go ahead then with the feed problem?

()

4 A

Now on the feed problem, they found that if they 5

overfeed the steam generators on a reactor or turbine trip, 6

that also will result in. maximum heat removal and contraction 7

in the RCS.

8 So if you've got both of these things going against you, 9

these B&W machines are really sensitive to it.

And it will

.10 really contract that RCS and you will lose your level on 11 it.

_ 12 Now Davis-Besse's problem was compounded during this 13 particular event because they were putting in auxiliary 14 f eedwater and the auxiliary feedwater is substantially 15 cooler than normal feed.

16 Now you've got a problem if you put too much f eedwater 17 in there at normal temperatures of maybe 350 degrees. Now 18 if you start jamming a lot of water in there at say 100 19 degrees or 110 degrees, you can see the problem that you 20 can run into real quickly.

21 Now while they were pursuing again this resolution of 22 our concern on how low the pressurizer. level went, 23 Davis-Besse's thoughts went like this.

24 During the November event, we had automatic initiation of

)

25 our auxiliary feedwater system.

That automatic initiation, l

t I

L

f621.02.10 29 HEE gsh 1

the automatic control point calls for 10 feet of cool water

(^h x,/

2 in that steam generator, a lot of cold water.

3 So they said, let's adjust the blowback setting.

And

()

4 then also, another thing, let's determine how low that 5

automatic control setting needs to be on the auxiliary 6

feedwater.

~

7 So we will just put'in just enough to assure that we have 8

natural circulation in the event we need it and no more than 9

that.

And this will minimize our contraction.

10 They were pursuing that with B&W.

11 Now in pursuing both of these issues, we first became 12 aware of the problem in November and December of '78, which 13 indicated to us that there may be a situation the plant 14 could get into where they could not only lose pressurizer O

15 level indication, but they could drain the pressurizer.

16 We had no previous knowledge of that possibility.

We 17 confirmed that in a telephone call to the licensee, and I 18 believe Mr. Tambling has previously given you documentation 19 of those phone calls.

-20 That's the reason that I did not provide them.

21 We confirmed that there were those possibilities.

Once 22 we knew that there was a possibility of draining the 23 pressurizer, then we raised at that time the possiblity that

)

i 24 that constituted an unreviewed safety question.

(O k'

25 Now could we just back up for a moment.

How did you come O

1621.02.11 30 HEE gsh 1

to the-conclusion that the possibility existed of draining

()

2 the pressurizer?

3 A-The licensee conducted their natural circulation 4

test in the summer of.1978.

One of the bits of information

({])

5 that they were going toget from that test was what is the 6

lowest level that is necessary in the secondary side of the l -

7 steam generator to assure that we have adequate natural 8

circulation?

9 They were going to then use that information to go back 10 and revise their automatic set point on the auxiliary 11 feed system to minimize the cold water in there and 12 contraction.

13 Well, when they got the information and they started to 14 revise the automatic control set point, B&W advised them that Gk>

15 they could not do this.

16 They were undcr the impression for niae months that that 17 was how they were going to go about it.

B&W said you c an't 18 revise that automatic control set point because the small 19 break LOCA assumes that you have 10 feet in there.

20 So you are invalidating the LOCA analysis if you do this.

21 And they said, although we don't believe that it would have 22 a detrimental effect or change the local results significantly, 23 it still is outside of the assumptions made in the LOCA 1

24 analysis.

()

25 So in discussing that and some upcoming power escalation l

m i ~

9621.02.12 31 HEE gsh 1

testing, the licensee said, well, we won't revise our set O) q, 2

point.

What we will do is we will install a dual level set 3

point control.

So if we get an auxiliary feedwater initiation

( ')

4 in the absence of a LOCA, it will contr.o1 it at the lower 5

level.

If we have a LOCA with -- if we have a LOCA, then 6

it will control it at the higher level.

7 So it would satisfy'the accident analysis, yet minimize

'~

8 the amount of cold water going in there if we don't really 9

need it.

10 So while they were.looking at this dual. level set point 11 and they were looking at some upcoming transient testing 12 which required them to keep their hands off to see the way 13 the plant would perform, and that would mean that the level 14 may go up to 10 feet, they said, we want to take manual 15 control of some of those items during this testing to 16 minimize the amount of cold water going in there so that we 17 don't get a loss of pressurizer level indication while we're 18 doing our testing.

19 And so the combination of these things as to why they 20 wanted to do this and we got into, well, up until this time, 21 you told us that there is no problem with voiding the i

22 pressurizer., Are you suggesting that that could occur now?

23 And it developed that there were certain conditions where 24 it could exist.

25 And that is when we identified it as a potential unreviewed O

$621.02.13 32

~

bHEEgsh I

safety quesion and requested the licensee to do an analyis

()

2-of a bounding case.

And that bounding case turned out to'be

.3 loss of f eed f rom 100 percent power with all of the reactor

(~

'4 coolant pumps running, I believe.

w) 5 0

-Was that analysis performed?

6 A

Yes, it was.

o -

7 0

What was the conclusion of it?

8 A

The conclusion was that the pressurizar would void, 9

you would lose all level, not just the indicated level.

You 10 would lose level in the pressurizer.

11 The steam bubbles would form in the reactor coolant system.

12 However,.they would as long as the reactor coolant pumps 13 continued to.run, they wouldn't coalesce ~.

They would be 14 mixed up, and eventually the high pressure injection system 15 would cause the situation to be corrected and the RCS would 16 refill.

17 The conclusion was in that there would not be any fuel 18 damage. It did not constitute en unreviewed safety question.

19 0

Who reached that conclusion?

20 A

Primarily, it was NRR with out input.

21 0

Who specifically in NRR?

22 A

This was reviewed by a group of people, the most 23 senior of whom was Brian Grimes in NRR.

24 0

Do you recall who else was involved with that

()

25 review?

O

7621.02.34 33 HEE. gsh 1-

-A.

Although I do not know all of the people that

()

2 reviewed ~it, I remember that Sy Weiss had some involvement.

3

.There were.several other. people that were involved.

().

4 Just a minute and I'll see if I can't find it.

5 (Pause.)

6 A

I'm sure the participants in this telephone call 7

that I'm going to give you were included in the telephone

-~

8 account that Tom Tambling provided you.

But they were 9

Brian Grimes, Guy Vissing, Sy Weiss.

From IE there was 10 Kirkpatrick, Jordan, and also Fairtile from NRR.

11 O

When was this analysis provided to you?

12 A

To the best of my knowledge, it was provided either 13 September 22nd or 23rd of 1978.

14 0

So it was.just before Christmas and in '78?

15 A

That's correct.

16 0

Now this, then, when it was analyzed by NRR, they 17 concluded that this was not an unresolved safety issue.

18 Is thet true?

19 A

That is correct.

20 0

When did they reach that conclusion?

21 A

on December 23rd. 1978.

22 0

That was when they reached their conclusion?

23 A

That was understood as a result of the telephone 24 conversation.

(b.

25

' O L

l

7621 03..!

34 e

HEE gsh _

1 0

Now, would you proceed then with your discussion of

()

2 Mr..Creswell's concerns related to this issue.?

3 Did that resolve his concerns?

(~')

4 A

Well, you see, the initial issue that Jim Creswell s.

5 had was how far did the pressurizer level go during that 6

event?

>~

7 That was determined'by the licensee.through some analyses 8

to be three feet below the lowest indicated level.

9 Now Jim Creswell in December, 1978, when we became aware 10 of the possibility of draining the pressurizer, he forwarded 11 a memorandum to me recommending that an investigation be 12 performed by the licensee to determine if they had pursued 13 resolving this matter in a timely fashion, is what it 14 amounted to.

Ok-15 There were some other issues involved in it, but this was 16 the one that was related to November.

17 0

Excuse me.

Was the investigation associated with a 48 loss of pressurizer level or with aeoiding the pressurizer?

19 A

It was associated with the less -- I will have to 20 refresh my memory by looking at the memorandum.

21 MR. HEBDON: Let's go off the record.

22 (Discussion off the record.)

23 MR. HEBDON: Let's go back on the record.

24 THE-WITNESS: The telephone conversation that I (3

25 ref erred to in which we confirned that the possibility

-s/

G ts._)

l

35 fp21.03.2~

HEE;gsh I

existed under certain conditions to void the pressurizer or

()

2 to drain the pressurizer, that telephone conversation occurred 3

December 18th, 1978.

()

4 BY MR. HEBDON:

5 0

Now this is with the utility?

6 A

This is with the utility.

That telephone 7

conversation did not involve Jim Creswell.

It was Tom Tambling 8

his supervisor and myself.

9 0

What was the reason for the call?

10 A

The reason.for the call was to, it appeared that the 11 information that they were giving us on dual level set p-41nt, 12 the reasons for not wanting to conduct the certain upcoming 13 transient testing without taking manual action.

Those 14 raised questions in our mind as to whether or not there were

_O' 15 conditions where the pressurizer could drain.

16 Now to that point, we really did not think about that 3

17 poss i bi lity. Excuse me. We thought about the possibility.

18 We asked the licensee if there were conditions where that 4

19 occurred and they said no.

20 So now we come to a situation where we have got a 21 change in direction where there are some situations where it 22 can avoid.

And this is the reason that we initiated the 23 call.

24 Before we understood that there wasn't a possibility.

Now

]k 25 we understand that there are.

What are these?

d-

l i

7621.03.3 36 e.' HEE.gsh

.1 And so at that time we told them that that was a potential

()

.2-

.unreviewed safety question and analysis would have to be 3

performed to determine if it was or it wasn't.

(])

4 That analysis would have to, may have to be reviewed by 5

NRR.

6 That was December 18th.

>m 7

December 19th, I informed Jim Creswell of the result of 8

that conversation, the same day, on the 18th.

The 19th, he 9

wrote a memo to me.

I t was n' t to me.

It was through me to 10

.the branch chief, Gaston Fiore111, at that time, recommending Il that an investigation be conducted on who and when did they 12 know about the possibility of voiding the pressurizer.

13 An investigation was subsequently performed and the 14 conclusions from that investigation were that the licensee O

\\'

15 had pursued it in a timely fashion.

16 Now.let me back up here a little bit.

It is your 17 understanding then that the purpose of the investication was 18 to look into the issue of the voidino of the pressurizer or 19-the loss of pressurizer level indication.

20 A

Well, to tell you the truth, until I just looked at 21 the words, you could not separate the two events because you 22 had to go back and look at the beginning of the loss of 23 pressurizer level indication issue to see when they became 24 aware of the pressurizer voiding problem.

(

25 And so you really had to consider them both together.

-()-

1 J

q P621.03.4 37

. HEE gsh 1

-But the memorandum that Jim Creswell directed to-Fiore111

)

2 to me specifically states and asks in the last paragraph that 3

the investigation be conducted to see when the issue of

()

4

' pressurizer voiding was first identified.

5 You could only. determine that from looking at both of 6

them together.

7 0

Now is it your understanding that the investigation

'~

8 that was conducted did look into this cuestion of when the 9

utility apparently reversed its position on whether or not 10 voiding could occur in the pressurizer?

11 A

I do not recall exactly.

I would have to read the 12 investigation report.

13 0

Is it your understanding that a determination or 14 a conclusion was reached as to when the utility reversed 7-15 that position?

16 Do you know when they reversed it?

17 A

I only know from my standpoint when I became aware 18 of it.

But I do not know when the utility either reversed 19 their position or the conditions existed all the time.

But 20 I just did not understand them and neither did Jim Creswell.

21 That possibility exists. But the conclusion of thh 22 investigation was that the licensee pursued the terms of the 23 investigation.

It says loss of pressurizer level indication 24 in a timely manner and f ashion.

25 0

But that is a different issue.

n v-

1621.03.5 38 HEE gsh 1

A In order to void the pressurizer, you have got to

()

2 move the' indicated level.

3 0

Yeah, but they supposedly conducted -- they looked -

([])

4 into this question of loss of pre ^surizer level indication.

5 A

Yes.

6 O

And they conclucea that, yes, you lose it, but it is t

7 not really a problem.

8 A

That's right.

9 0

But as a separate issue, it would seem that there 10 is also a question of whether or not the pressurizer a vally 11 voids.

1 12 And from what you're saying, at least your percept

.. is l

13 that they initially stated that they would not lose the --

l 14 that they would not void the pressurizer.

Akl 15 And they subsequently changed that position to take the 16 position that they would void the pressurizer.

17 A

That was my understandinc that they would not 18 void the pressurizer.

19 I believe now,.looking back in some of this documentation 20 that that conclusion could have been drawn perhaps sooner.

j 21 We perhaps could have raised that question earlier.

22 But in November, 1978, Jim Creswell and myself had a l

l 23 telephone conversation with the licensee to confirm that 24 there weren't any conditions under which the pressurizer

(

25 could void.

And we were, the licensee confirmed that that l

l

'621.03.6 39 HEE gsh I

was correct.

/~S

(_)

2 O

At.what time was this?

3 A

November of '78.

()

4 0

So in November of '78, it is your understanding 5

that the licensee told you that the pressurizer would not 6

void.

7 A

That's right.

~

8 0

But then in December, it is your understanding that 9

the utility then told you that the pressurizer would void.

10 A

That's right.

11 0

So that is obviously a case where they have 12 reversed their position.

13 A

It appeared to us to be the case. And you will see 14 from reading back in the December 19th, 1978 memo from Jim

('

15 Creswell through me to Fiore111, the second paragraph --

16 I might as well read this, to show that it is brought out 17 clearly.

18 "On December 18, 1978, P.r. Streeter informed me of the 19 results of a conversation that he and Mr. Tambling and 20 Mr. Knopp had with Mr. Domeck of the Davis-Besse staff.

21 Apparently, but under certain conditions, it is possible to 22 void t ie pressurizer by overheating the steam generators with 23 auxiliary feedwater."

24 The next-to-the-last paragraph said:

Mr.

S tree ter and I i

25 have asked the licensee on more than one occasion whether there l (~>s l

l l

f621.0 3. 7 -

40 HEE'gsh I

was a problem with voiding of the pressurizer and the rx

(_)

2 licensee response has been, no, there wasn't.

3 So this was the reason for Jim Creswell's recommendation

()

4 that the investigation be conducted, was because, partially 5

because of this change in our understanding of the 6

matter.

7 Q

Now is it your understanding that the investigation 8

that was conducted looked into this question of whether or not 9

the utility had been misleading you in their earlier 10 statements that the pressurizer would not void, whether they 11 had been simply misinformed or whether you had misunderstood 12 them?

.13 Do you have any f eeling for how that -- why that change 14 occurred between November and December?

15 A

I don't know if that particular matter is brought 16 out in the investigation report.

17 It was my understanding from that report that the 18 inspectors had reviewed how the licensee had pursued the 19 matter from the time that it was first identified in November, 20 1978 -- 1977, excuse me -- up to the point where NRR had 21 reviewed the analysis and determined that there was no 22 unreviewed safety cuestion.

23 Now that would have included, when the issue first came up of the pressurizer voiding and who knew it and if they

^4 25 pursued it in a timely fashion.

I don't know if that is l

C:)

l

621.03.8 41

, HEE gsh 1

specifically identifed in the report, but in my own mind I

()

2 was satisfied that the conclusion was that nobody was 3

hiding information.

Nobody was telling us that it wouldn't

{j 4

void and then say that it would void.

5 I felt that it covered the issue.

6 As I understood what you just said, they did tell you

~

7 that it wouldn't void and then told you that it would void.

4 8

Didn't I just. understand you to say that in November they 9

said that it wouldn't void and in December they said that 10 it would void?

11 A

That is correct.

12 O

What, in your mind, is the reason for that change?

13 A

In my opinion, it could have been two things. It 14 could have been either the licensee became aware of some f')

x 15 new information that they did not have when they told us 16 in November of '78 that it wouldn't void, which would have 17 caused them to change their position, or it could have been 18 somehow a misunderstanding on our part of what their previous 19 position had been.

20 Now it was my understanding in November of '78 that there 21 were conditions under which the pressurizer level ',ould 22 void.

23 Subsequently, in December, it turned out it was my 24 understanding that, hey, now there are conditions.

()

25 0

But you don't know for a fact which of those two O

7621.03.9 42 HEE gsh 1

explanations or possibly any other explanation is, in fact, p)-

2 the real reason why there was a difference in perception?

(_

3 A

That's right.

I might add that the copies of the

()

4

. documents which I'm going to furnish you after December, 5

we became aware through the licensee that there were certain 6

conditions under which you could void.

7 In retrospect, looki~ng back at the memorandum, or the

'~

8 memoranda that we have, there is enough information in there 9

to cause one to ask that question earlier than we did.

10 I didn't see it then, but I see it now, that perhaps there 11

.s eno.;gh information that the licensee had that I should 12 have baen aware of it earlier.

13 0

That the licensee had or that you had?

14 A

That the licensee had.

Excuse me.

That we had.

15 We had copies of these documents as we went along.

16 0

All right.

17 A

These documents that we had, I guess, to my 18 knowledge, with one exces

,a, Jim Creswell had copies of 19 all of these documents as we went along.

20 0

What is the one?

21 A

I believe it was an evaluation that there is a i

22 September memorandum in there that he subsecuently received 23 in October, I believe, but he did not have it before I had 24 it.

(

25

'O All right. Now this discussion then proceeded through CE)

r7621.03.10 -

43 HEE gsh 1

December and I guess-into the beginning of January.

( )'

2

-What happened next as far as Mr. Creswell's concerns were 3

involved?

(a) 4 A

The memorandum ' that Jim Creswe11 ' wrote to Fiore 111 5

was dated December 19th.

Four days later was when it was 6

resolved in the minds of RRR and us whether or not the 7

voiding represented an'unreviewed safety question.

~

8 So that was really the technical aspects of it were 9

revised then as far as the NRC position.

10 In early January of this year, Jim Creswell decided to 11 forward certain matters he considered to be generic to 12 sitting boards for B&W facilities for their c.onsideration.

13 So he wrote a memorandum to me recommending that I review 14 the matters and wrote a letter which was subsequently signed 15 by Jim Keppler and sent to our neadquarters and recommending 16 that the information be forwarded on.

17 one of those concerns was the pressurizer level problem.

18 He acknowledged in his memorandum that it was -- it had 19 been reviewed by NRR as not being a problem. However, he 20 still felt that although it wasn't a problem, it was sort 21 of ridiculous to have livensed plants with not adequate 22 instrumentation.

l 23 0

Was his concern associated with loss of pressurizer 24 level indication or with the voiding of the pressurizer?

25 A

I would have to look at the memo to be certain, but C?

1 j

F621.03. l l 44 IIEEgsh 1

I do know that even if he was-satisfied tnat the pressurizer

()

2

- would not void, he. was still concerned about the possible 3

- implications of GDC.13 in the maintenance of level during 4

certain anticipated operational occurrences.

()

5-0 Level indication?

6 A

Level indication.

7 0

Do you know if a determination was made by anyone

~

3 other than Mr. Creswell as to whether or not the loss of 9

pressurizer level constituted a violation of GDC-13?

10 A

To the best of my recollection, this issue was

.11 discussed and I was involved in some'of the conversations 12 with NRR.

13 And I guess there were some people that believed that it 14 was a violation of GDC-13, and there were other people 15 iho believed that it wasn't.

16 There was no clear-cut answer.

17 0

Was there a management position?

Was there an 18 official NRC position?

19 A

There was a management position in that the 20 analysis presented by Davis-Besse for the loss of f eed 21 f rom 100 percent power could void the pressurizer.

22 And during that anticipated operational occurrence, you 23 definitely have. loss of pressurizer level indication.

And 24 that there is no requirement to have the licensee do 25 something to avoid that.

There was tacit approval of n

v i

7621.03.12 45 HEE gsh 1

operating under a condition situation where you could lose

(

2 level indication.

3 You would have to say that --

(_j_

4 0

To your knowledge, though, did anybody specifically 5

address _the question of whether or not loss of pressurizer 6

level indication was a violation of GDC-13?

"~

7 A

Yes, but I don't know of any documentation prior 8

to January where it is documented that that issue.was 9

addressed.

10 0

Could you describe when and how that issue was 11 addressed?

12 A

Well, it was discussed in conversations between 13 Sy Weiss, NRR, and Region III, I&E headquarters personnel, 14 Ed Jordan and his group, Region III personnel -- we all O

15 talked about the loss of the GDC-13 aspect because that was 16 our first concern before the voiding.

Even in the absence 17 of voiding, our initial reaction was, okay, although it 18 won't void, this is an undesirable situation.

19 Is it contrary to GDC-13?

20 And as I said, although it is not documented in insoection 21 reports or, to my knowledge, telephone logs or anything, that 22 matter was discussec.

23 0

Do you personally recall hearing it discussed?

24 A

Yes.

But if I had to pinpoint specific individuals CT/

25 and when, I couldn't.

O

~

i

~

7621.03.13 46 HEE gsh

'l The only other reference I know to the GDC.13 issue

()

2 was subsequent to Jim Creswell's memorandum for forwarding 3

the inf ormation to boards.

()

4 That issue came out in headquarter's evaluation of the 5

cencerns.

And I believe the conclusion drawn there was it 6

had to be reviewed futher to determine if it was a GDC-13 7

problem or not.

3 ~

8 0

Do you know if that question has ever been 9

finally resolved as to whether or not it is a GDC-13 10 problem?

11 A

To my knowledge, at this time, there are still 12 questions on both sides on the staff's position of whether 13 or not it is a 13 issue.

14 O

So it is your understanding that it still has not

(_.

15 been resolved?

16 A

I have not seen a clear-cut position on the 17 matter, a documented position.

18 0

You mentioned that you prepared a letter that Mr.

19 Keppler subsequently signed forwarding Mr. Creswell's 20 concerns for the board notification.

21 Did you agree with Mr. Creswell's concerns or were you 22 simply forwarding his concerns basically without comment?

23 A

The first thing that I did was to go through each 24 one of the items and evaluate them.

I felt that that was

(

25 my responsibility as his supervisor.

O 1

521.03.14 47 HE2 gsh i

I did not feel that forwarding tne information to the

(_)

J ocerds was tne way to go aoout resolving the issues.

And 3

tha; is accumented in the memoranda.

/\\

4

'iy discareement in forwarcing to.he ocards is documen tea.

()

I wrote tne le tter.

I felt that they could oe resolved witain the staff on a generic casis going aoout it a different a

> ~

/

dir 3c tion.

3 fact was one proolem I had.

/

J Han did you feel tnat it should oe resolved?

IJ A

I felt how it should oe resolved if forwarded --

la tne responsioility over to NRR and requesting tnat they 12 evaluate the generic aspects of these avents.

13 fnet is accumented in the memo on the dif f erent courses I?

of action tnet I favor.

,!")

10 2

All riaht.

lo A

fas other objection that I had that I expre sseo to Ie Jim Creswell was some of tne concerns tnat are in tnat 13

aamoranour were not really pursued oy us otner then some of 1/

them were almost like hearsey.

23 For exams 19, the lancho 3eco event tna t occurrea, Jim 21 Creriell came across e memorandum at Dav i s-d e ss e end oefore, 2a I guess, evaluating thorougnly whetner or not it could even 8

2a occur at Davis-Besse, he recommenaea forwardino it down to 21 the ocard.

,,\\

i

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2; I thou:nc tnat tnat should have nad more field attention i

i t

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1

)621.'03.15 43 5:

i

HEE gsh I

before we sent it'down.

J( I 2

31milarly..with a breaker problem, suosequently turned 3

. out to 02 a generic issue.

And he was rignt.

(

'4 But the f act was that when we-sent the memo down, we didn't know if anybody had experienced those proolems or a-not.

i S~

./.

It turnea out that Davis-Besse hadn't.

3 30 I had some disagreement with now to approach tne 9

pr3clems more than with the technical aspects of them. The IJ pressurizer level issue specifically, I did not have 11 concerns related to that because I f elt comfortable with the 12 NRR and the NRC position that although there is a situation 13 where you can get into, that has Dean analyzed ana approved, 1;

I ac:epted that.

~

O-15 0

33 tnen you did not share "r.

Creswell's concern 15 with respect to the issue of pressurizer level?

Il A

lot suosequent to the evaluation that was performed

^

13 uy tne NRC.

I)

J At the time that he prepared his ocard notification?

f 23 A

th.

i 23 N3w as-I understand it, tnis material was s

22 aventually sent to the coards.

l 23 A

Now I would like to go ca:% just one step.

2; Cartainly.

s I

l 23 A

'inen I say that I did not shara Jim Creswell's

!O

-- vm w-w e-m rw e

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---,,-mne

d21.03.15 49 NEE gsh I

con:3rns acaut the pressurizer voiding, again, I would like to sly that I shared his concerns acout maintaining the a

inJi:ated level. Although I saw it as an oosrational

()

4 proolem and not a safety issue, I still felt that it was 3

en undesiraule situation and should be corrected, if a

po ssi ble.

~

I cia not share his concarns aoout, and I don't oelieve 4

5 thet he nad tnem et that point, as far as the safety

/

implications of the voiding since tnat hsd oeen dispositioned IJ oy.1RR.

11 Il 13 I?

la la 1/

13 li 23 21 22 24 2a 0

621.04..I 50 HEE gsn 1

0 Now these matters were ref e rring to the licensing 2

aoards.

3 A

Yes.

As e matter of f act, they were f orwarded I) 4 to more coards than Jim Creswell haa recommended.

He had identified some specifics.

5 Dur reviews had indicates that tnere were more plants

/

and to really comply with his request, although he nad only 3

identified specific coards to send it to, it was necessary

/

to sa nd i t to more.

10 I identified some and than subsequently, NRR identified 11 otners soova and ceyond what I had, where it should ce sant.

I 12 0

Do you know if any of these ocards has suosequently 13 taken any action with respect to these issues?

14 A

I have not.

I have no knowledoe of anything tnet 15 they have done with them.

13 Are you aware that Mr. Creswell discussed his 1.

con:arns witn Commissioners Bradford, Ane arn e, and their 19 staffs?

li A

Act at the time it occurred.

I heard aoout it 23 suosa quent -- I celieve it was suosequent to the T'AI 2 21 event.

It was quite sometime after.

2 0

Jo you i<nox whet -- what is your understanaing of 23

'4r. Creswell's conce rns that he expr essed to the commissioners?

24 A

I ouess the overall concern, to my understanding, 2;

that Jim. Cra swell expressec to the commissioners was one of O

gg @$$h l

521.04.2 51 4EE gsh I

celieving tnat Davis-Besse should.not be continued to e

operate based upon past performance and proolems that hao 3

ceen identied there.

4 0

Wnat is your opinion of that concern?

3 A~

I did not and do not share that concern. At the a

same time, I-will agree that the Davi s-Be sse facility has

/

not operated as well as' many others.

~

3 I would nave to say that Davis-Besse, in my opinion, is

/

proosbly representative of a new licensee first plant.

10 They have a lot of problems the first couple of years of 11 operation.

12 J

dare you involved in an investigation of Mr.

13 Creswell's concerns oy Mr. 4(ohle r and Mr. Foster oy I&E 14 Region III?

~

i Q'

13 A.

I 'vas involved to the extent that I arranged l$

for the investigation.

The investigation specialist was l:

1/

appainted of reports to tne assistant to the director in 19 our region.

1/

.#or the technical evaluation part of it, I arranged to 23 have Joe Konler participate in that investigation.

21

.iow once tne investigation starteo, the only involvement 2

I haJ was aqs'.vering questions that tne investicators hao of

't 23 my involvement and givin; information.

21 It was not a suoervisory-type of relationship with tne 23 people as far as directing the outcome of tne situation or-i O

l 9g@@ @3030'SA

$21.04.3 52 itEE gsh I

influencing it.

0 Was Mr. Creswell part of tne investigating qroup?

')

3 A

M3 was not.

a' 4

0 Is there a reason why he was not?

(v) 3 A

Tnere is and it was my decision to not include 5

him on that investigation, rather to have him function as e consultant to them.

>~

3 And if taey f elt tnat they needeo his input at any time,

then at theif request he could participate in the investigation 13 di rationele for doing that is no diff erent f rom in tne il leager or a person requesting an investigation from the 12 outside.

13 I wanted to assure that I had an objective view of the i1 situation, and I diJ that b/ choosina somecody who was not e

r

~

is dira: tly involveo.

15 0

Jo you have any f ee lin; f or wna t '4r. Creswe ll's 1/

reaction was to the results of the investigetion?

13 I Jon't believe tnat he was satisfieo with the 1/

results.

2J

.bw cy taet I don' t mean that he dion't oelieve tnet 24 tne o eople n ean't anne e acad Joo.

He just disegreed, 22 I ail ieve, nith tne conclusions.

23 fact is ny opinion, now I saw it.

2e nauld you explain your unaerstanding of wha t nis 23 aissatisfaction was with the results?

ggj{ i' w.e,b'% [bggeu u

v y K h

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b21.04.4' 53 NEE gsh i

A

  1. ell, he didn't.come to me and express 2

aissatisf action oy saying that I don't oelieve-that the J

investigation was-thorough.

I don't believe that they.did 4

a good job.

3 So it neeJs. to be done over.

6 I believs the fact that when he originally identified ths concern 'he nad, he 'is no diff erent than any of us.

If we

~

s

.8 thinK tha t there _ is a problem there, I oelieve that -- a real proolem we are nesitant to accept conclusions oy someone 10

-else after they have reviewed our concerns.

11 B( !tP. 00LSOM 12 2

You saia that you decided to initiate this 13 investigation oy Foster and Kohler?

4 14 A

No, I did not decide to initiate it.

That decision

(""

1.>

was reached oy the cranch chief af ter he hsa received tne 16 request from Creswell.

1,

.b w once he haa deciced that it would De performed, then Id I was the one wno made the cecision which was agreed to oy 1/

my management to have it done this way and giving my 23 rationale at that coint for the reason I was doing it.

21 2

.h w in terms 'of the sequence of events, did tnis 22 request for investigation precede th? request for tn3 23 ooara notification ?

24 A

Yes, it dia.

You're talking about Decemoer l>tn 22 and then I think January Stn.

That is the sequence.

And tne h

-m,.

621.04.5 54 HEE gsh i'

completion of the investigation, we're talking about

-0 2

- eeer"erv.

3 0

5) we have a requ3 st for.the^ investigation any a

()

4-

. request for ocard notification and a' trip to.1ashington by 3

Mr. Creswell to speak to Commissioners Bradford and Ahearne.

3 Were there other evidences of Mr. Creswell's somewhat l'

urgent concerns?

3 A

N).

J das he talking in the hallways witn you?

10 Was he urging things be done over cof f ee?

11 Give us a picture.

12 A

I think the memos that he wrote to me, especially 13 these ones that we're talking about in Decemoer for the 14 inves tigetion and board notification, were really an example

()

15 of nis continuing concerns with the operation of the

-16 Davis-Sesse plant.

1, I believe that it is feir to say that Jim Creswell li cellaveo up until the time ne left, es far as I know, tnat 19 Davis-Sesse shouldn't ce continued -- they shouldn't be allowed 2) to continue to operate caseo upon their perf ormance 21 nis to ry.

22 fnat was clear to me.

It was clearly. established-in a 23

on/ersation that Jim Cresw311 and I haa witn Soo Heishman, 21 the oranch cnief, of his fe311ngs.

s

)~

/-

2; w

'!nen was this conversation?

1 O

o Ofg $$$$d

621.04.5 55 HEE gsh i

A fnis was -- it ' couldn't have been a. week or two I(f

~

It was in Meren. I wo'uld say that it was 2

cefore the TMI.

3 procaoly ma/be a week before.

()

-4 ~

We knew of the concerns, we knew of the oasis for the o

c onc e rn s.

We were dealing with them in the manner that we 3

judged to os correct.

i So there was no secrecy aoout Jim Creswell's questions or

~

3 proolems or his position on Davis-Besse.

3 4o w, that is the best that I can describe it to you.

I 1]

can't say, well, he gave me this memo.

Such and su:h 11 recommended that the f acility be shut down.

1 12 It was.vercel, but it was no secret.

i 13 It was very clear.

i 14 Bf MR. HE3 DON:

('T

\\^'~

13 2

33 you know if an/one else within the I&E 15 organization, or in NRR, for that matter, snared 1r. Creswe ll's l/

con:ern that Javis-Sesse should De shut cown?

13 A

I can only say that from conversations that I heard 1/

going on in the halls and that I had with people that I 23 talted to, the general f eeling was one of tne ineptness of i

21 the Javis-33 sse pl ant.

24 Now tnat is their opinion.

2J I performed my own evaluation of that plant, its staff, 24 and :he proolems in January and Fecruary of tnis year and

(

25 my conclusion was tnat they were f ar from tne mocel facility.

O.e

56 621.04.,

HEE gsh i

Thef had many more problems as f ar as personnel errors and p).

management problems than the average utility would have.

2

(

3 dowever, if you go back and you look at people with new 4

licensees in the sense'that their first involvement in nuclaar

(}

5 power, it's their first plant, c.id you're talking aoout a i

6 plant the size of Davis-Besse with a type of technical specifications that they have, and try to get the oest i-5

omparison you can, it was my conclusion af ter doing that that they waren't really all that much different than a IJ comparaole utility.

j 11 I'm not saying tnat all of them, therefore, are okay.

12 I'm saying that they weren't really all that out of 13 balance.

14 3

Jid anyone in the course of these various la conn rsations indicate to you, or aid you get a feeling ths.

15 they felt tnat the ineptness of Davis-Besse was sufficient il to f3stif y shutting them down?

13 A

do.

I don't oeli3ve that anybocy shared the i

is conce rns of the. level of Jim Creswell's.

Tney would not go 2]

to tnat extant.

21 0

Nnat is your opinion of tne aoilities and 22 compe tence and maturity of V.r. Creswe ll?

J 23 A

Ine technical soility of Jim Creswell, I con't know 2;

of anyone-who has ever questioned tnat.

And oeing his

()J

/

25 supervisor, I don't question it as to the technical compe tence i

L O

l621.04.3 57 i

HEE gsh I

to conduct as good an inspection as anyone.

)

J He has nad some problems in the past and continued up 3

until the time he left, although I have s een some improvem?nt, L

j 4

at osing aorasive with people, licensees and colleagues alike, and naving personal cifficulties in that regard.

a a

I think that my appraisal of Jim Creswell, which was

> ~

/

signe d oy nim and me no more than a couple of days cefore

~

d D4I, pretty we 11 summarizes my f eelings and is an accurate appraisal of him.

IJ decause of his aorasiveness, in my opinion, this c aused li some celay in resolving issues, in clearly identifying wnat 12 nad to os done to resolve it, and to get the licensee to 13 cooperate and get tne issues reso3ved.

14 It was compounJed oy the fact that Davis-Besse was a 13 oifficult assianment in the f 'rst pl ace.

la 50 if you nave a cif ficult licensee to work witn and it alth tne a' rasiveness of an inspector, as Jim 1/

comoine o

13 Creswell ha;, you have a comoination that is very difficult.

1/

J You mentioned that you preparea an evaluation of 23

'Ar.

Creswell just oefore tha T41 accident.

21 aas tnat the only evaluation that you have percared 2

con:e rning Ar. Cre sxe ll ?

D 23 A

Ine evaluation I'm spea king of is en annual 2;

evaluation.

dow in conjunction with that annual evaluation, 2a we ' o annual audits of inspectors wnere we go out and se? how J

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i h j k o n b.a ? b id b:l:! ' D;,

3621.04.s 59 HE'i gsh I

the/ perform their inspections and things like that,

)

4 And if one called that an aopraisal, that was done. I s

ned some conversations with Jim Creswell as to what nis a

4 performance would have to be like in order to be promotea to

(

)

the 14 level.

2 So if on3 called that an appraisal informing him of wnat I was looking for, then I did that.

But other than thos3 0 --

4 3

things tnat I have just descrioed, tnat is the only appraisal

/

taa; I had Jone.

IJ J

Jid you indicate to Mr. Creswell that his performance 11 was not sufficient to warrant his promotion to the 14 level?

la A

fn at is correct.

13 BY MR. FOLSOM:

14 0

Wnen was this?

la A

Not too long after I arrived, s umme r of ' 7 3.

And 13 of course it was oovious when the aporaisal came out in 1/

dar:n that wnen there wasn't a recommendation down there for 13 promotion, tnet I wasn't re:ommencing it.

19 Again, it wasn't cased on t"o hnical espects.

But there 20 is more to i t, I feel, in a promotion to tnat level tnan tn?

25 te ca,1c al auility.

2J fou hsve to os sole to implement them.

2J a

Nn et was tne reason for tne discussion acout Mr.

2, Creswell's oromotaoility in the summer of '78?

,_r' '

ks 22 4

a911, he asd expressed a aesire to be promotea.

Ano

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f I

j J Qu v

'u b.ia00 k UU d-l.Olu u

i

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$21.04.10 59 HEE gsh I

so I felt ooligated to tell him before I could recommend J

2 tus; what I would be looking for.

3 And so it was initiated because of comments that ne maos

()

as f ar as w3nting to be promotec.

5 2

Comments he had made to you?

3 A

Yes, that is correct.

"~

0

.b a when vou had this discussion with him in the 8

sumner of ' tB, dia you make it clear to aim that you didn't feel that his performance was sufficient to justify 10 promotion?

11 A

In that I said that he would have to do tnese things la oefore I would promote him.

13 That in itself said that. I didn't see it then. There 14 wasn't any doubt in his mind or mine that changes had to 1;

ce made oefore I would recommend him for promotion.

15 0

Between the time of that aiscussion and tne 1.

evaluation that you prepered in Varch, did you f eel that 19 Ar. Creswell's pe r'ormance improved, deteriorated, or 19 remained approximately the same?

2J A

It improvec.

It was clear that he was making an 21 effart to carrect the probl3m wi th ni s aorasiveness.

22 There were improvements along tnet line. However, I'm sure, 2;

as m/ appraisel indicates, ne still v asn' t where he should 24 0e.

c

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a Jid you indicate in that appraisal that he haa bee n a

(,,

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621.04.11 60

' HEE gsh I

improving, although not yet to the level that you expected?

ihb 2

A l'm sure that I did because I told him that and 3

everyoody knew that he had improved.

4 0

Did you consider 'Ar. Creswell to be a trouole-maker?

()

a A

do, I don't see how anybody could consider him to a

De a troucle-maker.

The primary difficulty that everyone s -

/

that I'm aware of had with Jim Creswell was with his 3

aorasiveness.

9 dow he didn't go around, to my knowledge, ins tiga ting 10 people to do certain things, or stirring up people.

11 The only proolem -- the oiggest problem that he had was 12 in his personality.

And this is, oy personality, I mean his 13 a br as iv ene ss.

14

)

Have you ever discussed Mr. Creswell's conrarns 10 with the incidents that occurred at Davis-Besse with Mr.

15

' ell / or Mr. Denn, or any other employees of B&d?

I, A

Na.

13 a

Were you avare of the concerns that tney suosaquently 1/

raise d acout this issue of securino high pressure injection?

23 A

I wasn't

!. ware of i t until the presidential 21 commi ssion naarings were starteo ana it was on television, 2

I celieve.

Do you know of any other precursor events that are 23 J

24 relevant to the accident at TMI?

p (sJ 2a A

I don't know how you would define " precursor." If g

i

621.04.12 61 HEE osh I

you talk acaut TVI, where evidently there was a proolem with

$k i

people turning off nis pressure injec tion pumps prematurely 3

Decause of pre ssurizer level indication, then you would 2.sve (p!

4 to say that the Davis-Besse event of Septemoer, ' 7/ was a a

pre:ursor.

3 If you're talking acout the power-operated relief valve P ~

/

sti: king open, the Davis-Besse event, again, was a precursor.

3 J

Do you know of any others oesides the Davis-Besse

/

event in Sep tember?

!)

A Not directly.

As I mentioned earlier, it seems to il me that I recall suosequent to the TVI events hearing something 12 aoout a facility down in Region II that might have had a 13 proolem, but I'm not certain of that.

14

)

Do you nave any aoditional information tha t might 15 oe relevant to our inquiry into the events surrounding tne la accident at TVI?

II A

Could we go off the recora and let me think aoout 13 that for a minute?

11

'tR. HEBJON: Sure.

Let's go off tne record for a 23 minute.

21 (siscussion off tne record.)

24 THE iiI ri4E55 : I gue ss we're reaoy to ao back.

23 e

V.?. HESDO.J Okay, let's go bac k.

2 THE /iITNESS: I don't recall having any other

'v' 25 information that I would consider relevant

.o your m

621.04.13 62 l HEE csh I

investigation.

2 BY MR. HE3 DON:

3 J

Do you have anything else to add?

,1 4

A No, I don't have anything else.

./

5 M2. HESDON: Do you have any other questions?

5 BY MR. FOLSOM:

>~

O The questions asked of you about whether you were 3

aware of the issues raised oy this issue with Joseph Kelly

/

or Burt Gunn of B&W make me want to ask you, did you get IJ any feedoack at all from your investigation of Mr. Creswell 11 anc his concerns f rom B&d?

12 A

Tne feedoack that we received via the investigation 13 and again, since I wasn't directly involved in the it investigation, I aid not "sc it directlyl I got it Dy tn?

13 report.

la As you procaoly Know, the investigators made a trip to li Lyn:nburg in mic-Feoruary of this year.

The investigators 13 wer? trying to determine what B&W knew and the experienc e s 1/

at other f acilities on this loss of pressurizer level 23 inoi:ation prior to the Davis-Besse event occurring.

2s And at taet time, 534, as documented in tne investigation, 22 expr?ssed tnet it wes an undesiracle situation.

It was an 23 operational heada ne, I celieve, as they descrioed it, out it 24 wasn't a safety concern.

, es t

)

25 But tners was no mention anywhere in that investigation m

xjI

621.04.14-63 HE} gsh 1

aoout B&W having any concerns aoout the operator actions c v' 2

auring any events at Davis-Besse, including the September 3

event.

(j 4

I had no knowledge that anyone besides Jim Creswell had 5

concerns abaut shutting off those high pressure injection a

pum.as prematurely until, one, I got information on the oriefing and two, aoout two weeks ago wnen I revieweo the 3

deposition of Dick Knopp ana saw this memo f rom Denny Ross

/

to Karl Seyf rit.

It appears they both had the same concern 13 and then suosequently, it was shared by Jim Creswell.

11 I don't f.now if he knew of any of this memo from Ross to 12 Seyfrit or not.

13 I would only have to guess had he known, ne would have la crought it to my attention.

Is And that wasn't aone, so I assume that he didn't know aoout la it.

1,

' t.4. FOLSOD Okay.

la M7. HE3JON: Do you have anything else to add?

19 THE WITiiESS: No.

2]

'U. HE3 DON: That completes the interview. Thank you 21 very mucn.

22 (Anereupon, at 11: 00 a.m., the interview was 2a adjourned.)

24 2;

4